In Ashcraft et al. v. Tennessee (1943), the U.S. Supreme Court overturned a murder conviction on grounds that the confession used to convict was obtained through coercion, violating due process rights under the Fourteenth Amendment of the Constitution. The defendant, Ashcraft, had been subjected to continuous interrogation for over 36 hours without sleep or rest by law enforcement officials seeking a confession in relation to his wife's death. The court held that such treatment constituted psychological torture and thus any resulting confession could not be considered voluntary or reliable evidence against him.

In the dissenting opinion for Ashcraft et al. v. Tennessee, Justice Frank Murphy argued that the methods used to extract a confession from Ashcraft were unconstitutional and violated his rights under the Fourteenth Amendment's due process clause. He contended that subjecting an individual to 36 hours of continuous interrogation without sleep or rest was inherently coercive and could not produce a voluntary confession. Furthermore, he disagreed with the majority’s view that state courts should be given wide latitude in determining whether confessions are voluntary or coerced, arguing instead for stricter federal oversight on such matters as they pertain to constitutional rights protection. In essence, Justice Murphy believed this case represented an instance where police conduct had overstepped its bounds into coercion and intimidation tactics which fundamentally undermined fair trial principles.